Our Commitment
‍
‍At MAX, we are committed to conducting business with the highest standards of fairness, transparency, honesty, and integrity. We maintain a zero-tolerance approach to bribery and corruption in all forms and across all jurisdictions where we operate.Our reputation is built on ethical business practices, and we recognize that maintaining trust with our stakeholders including customers, partners, employees, investors, and the communities we serve requires unwavering commitment to anti-corruption principles.

Policy Statement
‍
MAX upholds all laws relevant to countering bribery and corruption in every jurisdiction in which we operate, including Nigeria, Ghana, and Cameroon. Our policy prohibits all forms of corrupt practices, including but not limited to:

•  Bribery of public officials or private parties
•  Offering, giving, receiving, or soliciting anything of value to influence business decisions
•  Facilitation payments of any kind
•  Fraudulent practices and misrepresentation
•  Money laundering and financial crimes

This policy applies to all MAX personnel, including employees, contractors, agents, and business partners who act on our behalf or alongside MAX.

What We Prohibit

Bribery and Corruption
‍
No MAX personnel or business partner may give, offer, promise, receive, request, or agree to receive any gift, benefit, or advantage in connection with MAX's business, except as expressly permitted under our detailed internal guidelines. This prohibition extends to interactions with both public officials and private parties.

Facilitation Payments
‍
Facilitation payments (unofficial payments made to expedite or secure routine actions) are expressly prohibited under all circumstances, regardless of local customs or practices.

Political Contributions
‍
MAX does not make political contributions under any circumstances. We recognize the risks that such contributions may be perceived as attempts to gain improper business advantages.

Improper Gifts and Hospitality
‍
While reasonable business courtesies are permitted in appropriate circumstances, MAX personnel must not offer or accept gifts, hospitality, or entertainment that could be perceived as intended to influence business decisions or create obligations.

Permissible Business Courtesies
‍
MAX recognizes that reasonable and appropriate hospitality and gifts can play a legitimate role in building business relationships. Business courtesies are permitted only when they:

  •  Serve a legitimate business purpose
  •  Are not motivated by a desire to exert improper influence
  •  Are reasonable in value and appropriate to the circumstances
  •  Are provided openly and transparently
 •  Comply with applicable laws and regulations
 •  Are properly documented and recorded

All gifts to public officials must receive prior approval from senior management and the Internal Control department. Any gifts or hospitality involving public officials or that exceed reasonable limits must be reported and documented in accordance with our internal procedures.

Charitable Contributions

‍MAX supports legitimate charitable causes that align with our values and benefit the communities we serve. However, we recognize that charitable contributions can present corruption risks if not properly managed.

All charitable contributions must:

  •  Be approved by MAX's Management Board
  •  Serve legitimate charitable purposes
  •  Be properly documented and transparent
 •  Not be made in exchange for business advantages or to influence officials

Our Governance Framework
‍
MAX's anti-corruption framework is built on four core values:

Accountability: We account for all actions and expenditures, particularly those involving public officials or business partners.
‍
‍Transparency: We communicate our actions openly and maintain accurate, detailed records of all business courtesies, expenses, and transactions.
‍
‍Evidence: We measure and monitor compliance through regular audits, reviews, and reporting mechanisms.
‍
‍Adaptability: We continuously review and update our policies to respond to changing regulatory environments and emerging risks.

Responsibilities

Management and Leadership

‍MAX's senior leadership is responsible for:

 •  Setting the tone for ethical business conduct
 •  Ensuring compliance with this policy across all operations
 •  Providing adequate resources for compliance training and monitoring
 •  Reviewing and approving high-risk transactions and relationships

All Employees
‍
Every MAX employee is responsible for:

  •  Understanding and complying with this policy
 •  Completing required anti-corruption training
  •  Raising concerns about potential violations
  •  Maintaining accurate records of business activities
  •  Reporting any suspected violations immediately

Business Partners
‍‍
We expect our business partners, including agents, consultants, vendors, and contractors, to adhere to standards consistent with this policy when acting on MAX's behalf or in connection with MAX's business.

Training and Awareness
‍‍
MAX provides regular training on anti-corruption laws and this policy to all personnel, with enhanced training for employees who:

  •  Have contact with public officials
 •  Work with business partners who interact with officials
  •  Have authority to enter into contracts or influence contracting decisions
‍
 Training is mandatory and must be completed within seven (7) days of hire or assignment to relevant roles.

Reporting Violations and Concerns
‍
MAX encourages all personnel to report suspected violations of this policy or anti-corruption laws. If you become aware of any actual or potential violation, you must report it immediately.

How to Report
‍‍
Reports can be made through the following channels:
‍
   • Anonymous reporting: Email to founder@max.ng

‍All reports will be treated seriously and investigated promptly. MAX is committed to protecting whistle-blowers from retaliation of any kind.

Protection Against Retailation
‍
MAX will not tolerate any retaliation against individuals who report concerns in good faith. Employees will not be discharged, demoted, suspended, threatened, harassed, or discriminated against for lawfully reporting compliance concerns.

Any person who retaliates against someone for reporting a concern in good faith will be subject to disciplinary action, up to and including termination.

Consequences of Non-Compliance
‍
Violations of this policy or applicable anti-corruption laws will result in serious consequences, including:

   • Disciplinary action up to and including immediate termination of employment
   • Termination of business relationships with partners and contractors
   • Potential criminal prosecution and civil liability
   • Significant financial penalties and reputational damage

Even minor infractions will be addressed through corrective measures, including mandatory refresher training.

Record Keeping
‍
MAX maintains accurate and transparent financial records with sufficient detail to identify recipients, purposes, and nature of all transactions, particularly those involving public officials or business partners. All business courtesies, gifts, hospitality, and expenses must be properly documented and recorded in accordance with MAX's internal procedures.

For more information about MAX's commitment to ethical business practices, please contact our Compliance team (internalcontrol@maxdrive.ai).